2. Why we Collect your personal information
3. Lawful Basis for Processing Information
4. What Information we collect and where from
4.1 Special Category Data
4.2 Third Party Collection of Personal Data
5. How Long we Keep Information For
6. Security of personal information
7. Children’s information
8. Your individual rights
10. Failure To Provide Personal Information
12. Automated Decision Making
13. Transfers To Third Parties
14. Transfers Outside Of The UK
15. Right to make a complaint
16. European Union Representation
17. Additional information
18. Policy Review and Amendments
WeThrive take the protection of your personal data very seriously and strictly adhere to the rules laid out by data protection laws and the General Data Protection Regulation (GDPR-EU and GDPR-UK).
This privacy notice gives you information on how we collect and process your personal data through your use of this site and any data you may provide if you contact us regarding our products and services.
We have appointed a data protection officer (DPO) who is responsible for monitoring and providing guidance with our GDPR status. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO/us using the contact information in Section 15 of this Notice.
2. WHY WE COLLECT YOUR PERSONAL INFORMATION
We collect your personal data for one of the following purposes:
- To manage communications between you and us.
- Where we need to perform the contract we have entered into with you.
- To provide you with information you have requested or which we may feel may be of interest to you.
- To ensure the safe operation of our website and to monitor the performance of our website.
- For marketing and advertising purposes.
- For recruitment purposes.
- For our financial management.
- For developing our products and services.
- For employment purposes.
3. LAWFUL BASIS FOR PROCESSING INFORMATION
We only collect and use personal information about you when the law allows us to. Most commonly, we use it where:
- The data subject (you) has given consent to the processing activity taking place such as for direct marketing or non-essential cookies on our website.
- If the processing is necessary for the performance of a contract, such as the supply of goods and services or the employer/employee relationship.
- If the processing is necessary for compliance with a legal obligation to which the controller is subject such as regulatory reporting or complying with requests for information from the courts.
- If the processing in necessary for the purpose of the legitimate interest pursed by us or our partners such as quality monitoring, surveys, and opt-out marketing activities.
Where legitimate interest is identified as a lawful basis, we will undertake a legitimate interest assessment which is a three-part test covering:
- The purpose test – to identify the legitimate interest.
- Necessity test – to consider if the processing is necessary for the purpose identified.
- Balancing test – considering the individual’s interests, rights or freedoms and whether these override the legitimate interests identified.
4. WHAT INFORMATION WE COLLECT AND WHERE FROM
We collect personal information from you, for example, if you register to our website, request product information, call us or use any of our services. The categories of personal information that we may collect, store and use about you include:
- Name, address, telephone number, email
- IP address
- Your country of birth, nationality
- Date of birth and gender
- Employment information
- Behavioural data
- Financial data
4.1 SPECIAL CATEGORY DATA
- We may collect the following special category data from you:
- Health data
- Racial or ethnic original
- Religious or philosophical beliefs
- Trade union membership
- Data concerning sex life or sexual orientation
- We will only process special category data where we have conditions under Article 9 of GDPR and Schedule 1 of the Data Protection Act 2018 allowing us to do so. These conditions are summarised below but more specific information can be found in our Appropriate Policy Document for Processing Special Category and Criminal Offences Data here.
- Article 9 (2) (b) Employment and Social Security/ DPA Schedule 1 Part 1 Employment and Social Security – all matters of employment including the payment of benefits such as sick pay, matters relating to the assessment or implementation of reasonable adjustments for disability.
- Article 9 (2) (g) Substantial Public Interest/ DPA Schedule 1 Part Insurance, Preventing or Detecting Unlawful Acts, Preventing Fraud, and Suspicion of Terrorist Financing or Money Laundering – all instances relating to the identification, investigation, prevention, or reporting of, criminal offences, misuse of funds, identification of persons or businesses under sanction, etc., and the actions which may follow this.
- Article 9 (2) (a) Explicit Consent – such as for the production of publicity materials which reveals special category information such as disability.
- Article 9 (2) (h) Health and Care/ DPA Schedule 1 part 1 Health or Social Care – matters relating to occupational health.
4.2 THIRD PARTY COLLECTION OF PERSONAL DATA
We may also collect your data through Third Parties such as Salesforce, LinkedIn, ZoomInfo, and HMRC. If you wish to know more about our receipt of your data from third parties, please use the contact details in Section 17 of this Notice.
5. HOW LONG WE KEEP INFORMATION FOR
We pride ourselves on ensuring that your personal data is only retained for the period that we need it for, or in accordance with laws, regulations and professional obligations that we are subject to. All personal information collect has a defined retention period, which is in-line with our retention policy. If you would like to find out how long your information is being retained, please Section 17 of this Notice.
6. SECURITY OF PERSONAL INFORMATION
We take the responsibility for protecting your privacy very seriously and we will ensure your data is secured in accordance with our obligations under the Data Protection laws. We have in place technical and organisational measures to ensure personal information is secured and to prevent your personal data from being accessed in an unauthorised way, altered or disclosed. We have in place a robust access control policy which limits access to your personal data to those employees, contractors and other third parties who only have a business need to know. The processing of your personal data will only take place subject to our instruction.
We have policies and procedures to handle any potential data security breaches and data subjects, third parties and any applicable regulators will be notified where we are legally required to do so.
We have ensured that all employees have had information security and data protection training. If you would like more details of the security we have in place, please see Section 17 of this Notice.
7. CHILDREN’S INFORMATION
We do not knowingly collect information on children. If we have collected personal information on a child, please contact us immediately using the details in Section 15, so we can remove this information without any undue delay if this is appropriate.
8. YOUR INDIVIDUAL RIGHTS
In this Section, we have summarised the rights that you have under General Data Protection Regulation. Some of the rights are complex, and not all the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
Your principal rights under General Data Protection Regulation are:
- Right to Object
- Right of Access
- Right to be informed
- Right to Rectification
- Right to Erasure
- Right to Restrict Processing
- Right to Data Portability
The right to object
You can exercise this right if:
- Processing relies on legitimate interest.
- Processing is for scientific or historical research.
- Processing includes automated decision making and profiling.
- Processing is for direct marketing purposes.
The right of access
- You or any third party acting on your behalf with your authority may request a copy of the personal data we hold about you without charge.
- We will ask to verify your identity or request evidence from the third party that they are acting on your behalf before releasing any personal data we hold about you.
The right to be informed
- We are required, to provide clear and transparent information to you about how we process your personal data. This privacy notice addresses this right.
The right of rectification
- If you believe the personal data we hold about you is incorrect or incomplete you have the right to correct this and you may exercise this right along with the right to restrict processing until these corrections are made.
The right to erasure
- If there is no legal basis or legitimate reason for processing your personal data, you may request that we erase it.
The right to restrict processing
You may ask us to restrict the processing of your personal data. This means we will still hold it but not process it. This is a conditional right which may only be exercised when:
- Processing is unlawful.
- We no longer need the personal data, but it is required for a legal process.
- You have exercised your right to object to processing and require processing to be halted while a decision on the request to object is made.
- If you are exercising your right to rectification.
The right to data portability
- You can request that your personal data is transferred to another controller or processor in a machine-readable format if:
- Processing is based on consent.
- Processing is by automated means (i.e. not paper based).
- Processing is necessary for the fulfilment of a contractual obligation.
If you have any question about these rights, please see Section 17 of this Notice.
Where you have given consent for processing, or explicit consent in relation to the processing of special category data, you have the right to withdraw this consent at any time, but this will not affect the lawfulness of processing based on consent before its withdrawal.
10. FAILURE TO PROVIDE PERSONAL INFORMATION
Where we need to collect personal data by law or in order to process your instructions or perform a contract we have with you and you fail to provide that data when requested, we may not be able to carry out your instructions or perform the contract we have or are trying to enter into with you. In this case, we may have to cancel our engagement or contract you have with us, but we will notify you if this is the case at the time.
12. AUTOMATED DECISION MAKING
Your personal data may be used in decision making based on profiling but we do not make any decisions based solely on automated decision making (a decision made solely by automated means without any human involvement)/profiling (automated processing of personal data to evaluate certain conditions about an individual). While we do not make any decisions with a legal effect based solely on automated decision making (making (a decision made solely by automated means without any human involvement), we do undertake limited profiling for purposes of direct marketing to share relevant content, webinars and events that may be of interest to the individuals based on their industry, topic interests and their role within their organisation. Such profiling may also include determining prospects for offers based on company profiles, industry, size, etc. You can opt out of this at any time.
13. TRANSFERS TO THIRD PARTIES
WeThrive may disclose your personal data, listed in Section 4 to some third parties to help us deliver our services/products. All third parties are contractually bound to protect the personal data we provide to them. We may use several or all of the following categories of recipients:
- Business partners, suppliers, contractors for the performance of any contract we enter into with them or you.
- Companies within our group where necessary for administrative purposes and to provide services to you.
- Third parties that support us to provide products and services e.g. IT support, cloud-based software services, providers of telecommunications equipment).
- Marketing services providers.
- Payment service providers.
- Recruitment service providers.
- Professional advisors e.g. lawyers, auditors.
- Web analytics and search engine provider to ensure the continued improvement and optimisation of our website.
14. TRANSFERS OUTSIDE OF THE UK
In this section, we provide information about the circumstances in which your personal data may be transferred and stored in countries outside the UK.
We may share personal information to third parties outside of the UK. Any personal information transferred will only be processed on our instruction and we ensure that information security at the highest standard would be used to protect any personal information as required by the Data Protection laws.
Where personal data is transferred outside of the UK to a country without an adequacy decision, we will ensure appropriate safeguards are in place prior to the transfer. These could include:
- Standard Contractual Clauses
- Binding Corporate Rules
- An exception as defined in Article 49 of the EU GDPR
For more information about transfers and safeguarding measures, please contact us using the information in Section 17.
15. RIGHT TO MAKE A COMPLAINT
We take any complaints about our collection and use of personal information very seriously.
If you think that our collection or use of personal information is unfair, misleading, or inappropriate, or have any other concern about our data processing, please raise this with us in the first instance.
To make a complaint, please contact us via email on firstname.lastname@example.org .
Alternatively, you can contact us:
By Post: 44-46 Old Steine, Brighton, East Sussex BN1 1NH
By Phone: 01273 921788
Alternatively, you can make a complaint to the Information Commissioner’s Office:
By Post: Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
By Website: Click Here
By Email: Click Here
By Phone: 0303 123 1113 (Local rate) or 01625 545 745 (National rate)
16. EUROPEAN UNION REPRESENTATION
We do not currently target customers located inside the EU and therefore do not currently have an appointed representative.
17. ADDITIONAL INFORMATION
18. POLICY REVIEW AND AMENDMENTS
We keep this Policy under regular review. This Policy was last updated on 31/05/2023.
We reserve the right to update this privacy notice at any time, and we will provide you with a new privacy notice when we make any substantial updates. We may also notify you in other ways from time to time about the processing of your personal information.